State v. Anderson, 997 N.W.2d 616

Aaron Anderson was charged with terrorizing, simple assault on a police officer, preventing arrest, solicitation of a minor, and indecent exposure after a 911 report of a man making sexual advances to a minor.
Officers found Anderson naked in a business restroom, detained him, read Miranda warnings, and initially seated him uncuffed in the squad car while arranging jail intake.
When officers attempted to secure handcuffs for transport, Anderson exited cooperating but then kicked an officer, stiffened and grabbed the patrol car, and officers used force to place him back into the rear seat and re-secure him.
During transport to a medical clearance, Anderson made explicit threats to an officer (e.g., shooting the officer in the lung; taking a piece of his skin) and later was medically cleared and booked.
After the jury convicted on all counts, Anderson moved for acquittal under N.D.R.Crim.P. 29; the district court denied the motion. On appeal Anderson challenged the sufficiency of the evidence for the terrorizing and preventing-arrest convictions; the Supreme Court affirmed.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Anderson)	Held
Sufficiency of evidence for terrorizing (intent/recklessness and threat)	Anderson made explicit threats; officer found statements disturbing; jury could find reckless disregard for causing fear, particularly given evidence of self‑induced intoxication	Officer only gave a "lukewarm" confirmation of alarm; Anderson was incoherent and lacked requisite intent	Affirmed — evidence sufficient; jury could find reckless disregard (self‑induced intoxication negates required awareness) and that statements were threatening
Sufficiency of evidence for preventing arrest (did resistance occur after arrest was complete)	Anderson’s resistance impeded officers’ efforts to effectuate transport/booking and required force; preventing arrest covers the process of effecting an arrest	Arrest for misdemeanors had already been completed, so later resistance could not constitute preventing arrest	Affirmed — preventing arrest includes actions impeding the process of effecting an arrest; sufficient evidence under analogous precedent

State v. Hannah, 873 N.W.2d 668 (2016) (standard for reviewing sufficiency of the evidence)
State v. Rufus, 868 N.W.2d 534 (2015) (sufficiency review principles)
State v. Brossart, 858 N.W.2d 275 (2015) (elements required to convict for terrorizing)
State v. Skarsgard, 745 N.W.2d 358 (2008) (preventing arrest conviction sustained where defendant resisted placement into patrol car)